Vincent Duncan vs. James Duncan
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VincentVincent a man of Colour
James DuncanJames Duncan

In the St Louis Circuit CourtCircuit Court , MissouriMissouri
Action of assault & Battery & false imprisonment

The deposition of Reason Neighswonger taken before me a Justice of the CountyCircuit Court
CourtCircuit Court in and for the county of St LouisSt Louis in the State of MissouriMissouri, pursuant to the
annexed notice, on the thirty first day of July in the year of our Lord One thousand eight hundred and thirty between the hours of eight and ten of the clock of the
forenoon of the said day, at my office in the city of St LouisSt Louis in said county
to be in evidence on the part of the plaintiff, in the above title

Reason Neighswonger, of lawful age, being produced, examined & sworn
on the part of the plaintiff, deposes & says, that he has known the plaintiff who
is here present for nine or ten years certain, that he first knew him at the SalineSalinelick
in the State of IllinoisIllinois, that he knew him there at the time the convention to form
or constitution for the State of IllinoisIllinois, that he knew said plaintiff some few days
before that time, but does not know how long, that the plaintiff at that time that
was claimed as the slave of one DuncanDuncan in the State ofKentucky KentuckyKentucky, and is hired
to work at the said SalineSaline as this affiant understood from the son of said DuncanDuncan
that in a conversation between said affiant and a son of said DuncanDuncan
that in a conversation between said affiant and a son of said DuncanDuncan , whose name
said affiant does not now recollect, this affiant propose to purchase the plaintiff,
and offered him a Mill valued at five hundred and fifty dollars for said plaintiff,
he agreed to take it, but that in a conversation shortly after had with the said son of
the said DuncanDuncan he the said Son Stated that the said plaintiff was to be free at his
father's death, and this affiant further states and says that the said son of the
said DuncanDuncan , at the time this conversation took place had Drank pretty freely
and was little intoxicated; Inconsequence of this declaration and information
received from W Robert Frankhouser, that the plaintiff was entitled to his
freedom, this affiant refused to trade for the said plaintiff, that this affiant
says that he knew the said plaintiff at the said SalineSaline for about three or four
consecutive years, that said plaintiff during that period worked at the SalineSaline
aforesaid and that the greatest part of the time with this affiant, who was
assisted by said plaintiff in the laying tubes for conducting Salt water to the furnace,
that to the best of the Knowledge of this affiant, the said plaintiff remained in
the State of IllinoisIllinois during the time aforesaid to wit three or four years.
Without leasing said State. that said plaintiff laboured for said Frankhouser
for better than a year during which time said deponent was in the employ of
said Frankhouser is a CarpenterCarpenter , that said plaintiff was also employed by one
RichardsonRichardson . That said plaintiff together with one Bobb Smith, a black man
rented a SalineSaline and worked it on their own account for about two or three

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that the aforesaid RichardsonRichardson kept a tavern and that the plaintiff remained in
his employ something like two or three weeks as for as this deponent can recollect.

Question by plaintiff, Is your recollection distinct as to the date & time that you
have spoken of? Answer, No. that the time is so long sinceelapse that
he cannot recollect. Question. by Same, Where is your place of residence
Whom you are at home or where do you now reside? answer, in like County
State ofIllinois IllinoisIllinois and about three miles from NaplesNaples about one hundred and ten
or fifteen miles from this city of St Louis County aforesaid

Question by the defendant. Did you know the plaintiff at the time the
convention of the State ofIllinois IllinoisIllinois to form a constitution sat? Answer I knew
the plaintiff at the time the convention or in about that time, I do not know
Who brought him there, I understood he was from KentuckyKentucky, the first time I saw
the plaintiff he was at the SalineSalineTavern and General Hardgraves,and
but do not know in whose employ said plaintiff was, said plaintiff was working
about said Tavern and worked with him many says, that said deponent
was employed by Frankhouser and during that time the said plaintiff worked with
him the said deponant and believes that the plaintiff was then employed by said
Frankhouser, That he said deponent doesnot know whether said plaintiff was
hired by DuncanDuncan , but that he always understood it to be so, and that the boy
worked for himself and paid for his time. Just as I was coming up On
the said farm ford's ferry, Mr. DuncanDuncan and myself met, I asked him where
he would get his load of salt from, he answer he did not know from what
furnance he would get it, but excepted to get it from the plaintiff because said
plaintiff was hired and he excepted to get the salt for his labour.

Question by the defendant at what time, year, when and where, were you
in any wise acquainted as seen the plaintiff? the first time that I saw him
was at, as I can now recollect, at one Hardgraves some short time after the
convention. Question by same, where did you Mr. DuncanDuncan get his load of salt?
Answer at the time I met DuncanDuncan with a [ waggon ] on the road from ford's ferry
to the Saline Duncan said to me that he was to take a load, but would bee the
plaintiff he did not know until he would see the plaintiff, and does not know
Whether said DuncanDuncan got his load of salt there or elsewhere, and that at that
time said plaintiff was working for himself, as this deponent believes, that
this transaction took place considerble time after the convention, that the said
DuncanDuncan who I met on said road with the [ waggon ] is the same one, who offered
to sell me the plaintiff as above stated, and which purchase or contract did not take
place for the reason above mentioned. Does not know who Brought the plaintiff
in the State ofIllinois IllinoisIllinois. That he knows of said DuncanDuncan Bringing with him, in
[ waggons ], Cider, Brandy, Apples and other produce to sell at the SalineSaline lick, &
this is